1. Introduction
1.1  New Appointments Group (NAG) is committed to conducting its business with honesty and integrity and aims to achieve the highest possible standards of service and ethical standards in all of its practices. 
1.2  We expect all staff to maintain the same high standards too; however, all organisations face the risk of things going wrong and sometimes malpractice and wrongdoing can take place. We take malpractice and wrongdoing very seriously and aim to prevent and eliminate any wrongdoing or malpractice within the organisation.  
1.3  We therefore encourage all staff to raise any concerns they may have about malpractice or wrongdoing within the organisation freely and without fear of suffering a detriment or dismissal to enable us to eliminate and prevent wrongdoing or malpractice within the organisation. 
1.4  We will treat any concerns raised seriously and will protect and support any individual who makes a disclosure in line with this policy.
1.5  We will make all staff aware of the existence of this policy and where it can be accessed.
1.6  This policy does not form part of any contract; NAG reserves the right to amend this policy at any time without prior notice.

  1. Who can raise a concern under this Policy?

 

2.1       This policy applies to all workers, including employees and agency workers.

 

2.2        No qualifying length of service is required in order to raise a concern under this policy. 

 

  1. When to use this Policy

 

3.1       This policy should be used to report concerns of malpractice or wrongdoing in relation to NAG’s activities where you have information which you reasonably believe tends to show one or more of the following:

  • that a criminal offence has been committed, is being committed or is likely to be committed (excluding those in relation to bribery and corruption, which should be reported using the procedure set out in the Anti-Bribery and Corruption Policy); or 
  • that a person has failed, is failing or is likely to fail to comply with any legal obligation to which he or she is subject (excluding those in relation to bribery and corruption, which should be reported using the procedure set out in the Anti-Bribery and Corruption Policy); or
  • that a miscarriage of justice has occurred, is occurring or is likely to occur; or
  • that the health or safety of an individual has been, or is being or is likely to be endangered; or
  • that the environment has been, is being or is likely to be damaged; or
  • that any of the above malpractices have been, are being or are likely to be deliberately concealed.  This applies whether the malpractice has already occurred, is currently in progress, or is likely to happen in the future.

 

3.2    You must reasonably believe that the disclosure is being made in the public interest.

 

3.3   It doesn’t matter if you are mistaken about your concern, but you must have information that tends to show some malpractice or wrongdoing rather than an opinion or a feeling. 

  1. Disclosures that are not covered by this Policy

 

4.1   You will not qualify for protection under this policy if you commit an offence in making the disclosure, or if you disclose a matter that is subject to legal, professional privilege (for example, correspondence between NAG and its lawyers regarding a specific case).

 

4.2   If your concern relates to your own treatment as an employee of NAG, including personal circumstances at work, you should raise it under the NAG Grievance Procedure, unless you reasonably believe that the matter is in the public interest.

 

4.3   If you are an Agency Worker through NAG and your concern relates to your own treatment or personal circumstances at work, you should raise it under NAG’s *Complaints Policy & Procedure.

 

4.4   If you are an Agency Worker through NAG and you wish to raise a concern of suspected malpractice or wrongdoing in relation to a hirer’s activities, you may need to raise the concern directly with the hirer in line with their own Whistleblowing Policy.

 

4.5   Any other concerns about NAG’s services generally which are not related to the types of wrongdoing or malpractice covered by this policy should be raised under NAG’s Complaints Policy & Procedure.

  1. How to raise a concern

5.1  If you have any concerns that fall into the category of the types of malpractice or wrongdoing covered by this policy, you should in the first instance make a disclosure to your immediate Line Manager if you are an employee of NAG, or to the NAG Consultant who is responsible for managing your assignment if you are an Agency Worker through NAG.

 

5.2  If, for any reason, you feel that you cannot tell your immediate Line Manager or the Consultant responsible for managing your assignment, you should raise the issue with NAG’s Operations Director: -

 

Jo Stevens

New Appointments Group

Innovation House, Discovery Park

Sandwich, Kent  CT13 9FF

 

01304 227722 or 01795 416616

J.Stevens@newappointmentsgroup.co.uk

 

5.3  If you have made a disclosure and are still concerned, or the matter is so serious that you feel you cannot discuss it with any of the persons named above, you should raise the matter with NAG’s Managing Director: -

 

Amanda Barnett

New Appointments Group

Innovation House, Discovery Park

Sandwich, Kent  CT13 9FF

 

01304 897345

A.Barnett@newappointmentsgroup.co.uk

 

5.4   A disclosure of a concern can be made by telephone, in person or in writing (including by email).  However, it is preferable for the disclosure to be made in writing so that we can keep an exact record of your concern. 

 

5.5  You are not expected to prove the truth of your concern beyond reasonable doubt or provide any evidence; however, you will generally need to provide the following information as a minimum:

 

  • the nature of the concern;
  • why you believe it to be true;  
  • the background and history of the concern; and 
  • relevant dates where possible.

 

5.6  You can raise any concerns anonymously; however, we encourage you to give your name when reporting your concern wherever possible because it may be more difficult for us to protect your position or give you feedback on the outcome of investigations if you choose to remain anonymous.

 

5.7  You may wish to consider discussing your concern with a colleague before raising it formally under this policy.  You can also choose to raise a concern under this policy alone or with a colleague; however, it is in the interests of all parties to maintain confidentiality once you have raised a formal concern.

 

  1. How we respond to concerns raised under this Policy
  1. We are committed to ensuring that all disclosures raised in accordance with this policy will be dealt with objectively, consistently, fairly and professionally.
    1. We will take the time to listen to any issues raised and arrange a meeting as soon as possible to discuss your concern (unless the concern has been raised anonymously).  The aim of the meeting will be to establish the background and facts in order to help us decide whether and how to carry out any subsequent investigation.  We may ask you for further information about the concern raised, either at this meeting or at a later stage.
    1. You may bring a colleague or trade union representative to any meeting that takes place.  The companion must respect the confidentiality of the disclosure and any subsequent investigation.
    1. Any concerns you raise in line with this policy will be recorded in our Whistleblowing Report Register.
    1. After the meeting, we will decide how to respond.  This will usually involve making internal enquiries in the first instance, but it may be necessary to carry out an investigation at a later stage which may be formal or informal depending on the nature of the concern raised.  We will endeavour to complete investigations within a reasonable time.
  1. We will keep you informed of the progress of the investigation as it is carried out and when it is completed, and give you an indication of the timescale for any actions or next steps that we may take.  We cannot inform you of any matters that would breach any duty of confidentiality owed to others.
    1. We will consider any concerns raised anonymously at our discretion, taking into account factors such as the seriousness of the issue raised, the credibility of the concern and the likelihood of confirming the allegation from other sources.  However, concerns that are expressed completely anonymously are much less powerful and are difficult to investigate.  It may also be difficult for us to provide you with feedback if you cannot be contacted.
    1. If disciplinary or other proceedings follow the investigation, we may need to ask you to come forward as a witness to help us take appropriate action to end the wrongdoing.
  1. Confidentiality

7.1  All concerns raised will be treated as confidential and every effort will be made not to reveal the identity of any individual who raises a concern.  Unless the law requires otherwise, we will only make disclosures to third parties or other staff with your consent.

  1. Raising your concern externally (exceptional cases)

8.1  The main purpose of this policy is to give all our staff the opportunity and protection they need to raise concerns internally.  We would expect that in almost all cases raising concerns internally would be the most appropriate course of action in order to resolve the issue.

 

8.2  However, if for whatever reason you feel you cannot raise your concerns internally and you reasonably believe the information and any allegations are substantially true and in the public interest, the law recognises that it may be appropriate for you to raise the matter with another approved person, such as a regulator, professional body, or an MP.  A list of the relevant prescribed people and bodies that you can raise a concern with is available on the GOV.UK website via the following link: 

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/510962/BIS-16-79-blowing-the-whistle-to-a-prescribed-person.pdf.

 

8.3  We strongly encourage individuals to seek appropriate advice before reporting a concern to an external person.  Public Concern at Work is a leading independent charity whose main objective is to promote compliance with the law and good practice in the public, private and voluntary sectors. They are a source of further information and advice and operate a confidential helpline.  ACAS also operate a free confidential helpline that you can contact for advice.  The contact details for both organisations are set out in the information and contacts section under paragraph 10 below.

 

  1. Protection and support for those raising concerns

 

9.1  We hope that all staff will feel able to voice their concerns freely under this policy. 

 

    1. NAG is committed to good practice and high standards and to being supportive of staff who raise genuine concerns under this policy, even if they turn out to be mistaken.
    1. Any individual raising a genuine concern must not suffer any detriment as a result of doing so.  If you believe that you have suffered such treatment, you should inform the Managing Director immediately. 
    1. NAG will not tolerate any harassment or victimisation of individuals who raise concerns about wrongdoing or malpractice in the workplace.  No member of staff may threaten or retaliate against an individual who has raised a concern.  Any person involved in such conduct may be subject to disciplinary action.
    1. To ensure the protection of all our staff and the integrity of our business, those who raise a concern frivolously, maliciously and/or for personal gain and/or make an allegation they do not reasonably believe to be true and/or not made in the public interest may also be subject to disciplinary action. 
    1. If you are not happy with the way in which a matter has been addressed or dealt with you should raise it formally through NAG’s Grievance Procedure if you are employed by NAG, or through NAG’s Complaints Policy & Procedure if you are an Agency Worker.
  1. Further information and contacts

 

10.1 If you have any queries about the application of this policy, please contact the Managing Director in the first instance.

 

10.2 Public Concern at Work is a source of further information and advice.  It also provides a free helpline offering confidential advice on 020 7404 6609.  Further information is available on their website at www.pcaw.co.uk.

 

10.3 The Advisory, Conciliation and Arbitration Service (ACAS) also has a free helpline that you can contact for further advice.  The ACAS telephone number is: 0300 123 1100 and the helpline is open Monday to Friday from 8am to 8pm and Saturday from 9am to 1pm.  The website can be found here: www.acas.org.uk

 

10.4 If you are a member of a recognised trade union, you can also seek information and advice from your trade union representative.



Issue 1: 15-Dec-17

+44 (0)1795 416600
New Appointments Group,
Innovation House, Innovation Way,
Discovery Park,
CT13 9FF, Sandwich, Kent